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This presumes that the ambient air temperature is almost the same as the
surface temperature; if the air temperature were much higher or lower
than the surface temperature, the actual temperature of the LM35 die
would be at an intermediate temperature between the surface
temperature and the air temperature. This is expecially true for the TO-92
plastic package, where the copper leads are the principal thermal
path to carry heat into the device, so its temperature might be closer to the
air temperature than to the surface temperature